Comment Number: 522418-06679
Received: 7/7/2006 12:39:52 AM
Organization: AmeriplanUSA
Commenter: Catherine Nolin
State: CT
Subject: Business Opportunity Rule
Title: Notice of Proposed Rulemaking
CFR Citation: 16 CFR Part 437
No Attachments

Comments:

July 6, 2006 Federal Trade Commission/Office of the Secretary, Room H-135 (Annex W) 600 Pennsylvania Avenue, NW Washington, DC 20580 RE: Business Opportunity Rule, R511993 Dear Sir or Madam: I am writing this letter because I am TOTALLY concerned about the proposed Business Opportunity Rule R511993. In its present form, I believe this could prevent me from continuing as an independent business owner. I understand that part of the FTCs responsibilities is to protect the public from unfair and deceptive acts or practices, however... some of the sections in the proposed rule will make it very difficult if not impossible for me to sell as a direct marketer, and independent business owner. What happened to being an American and having this great country 'encourage' the great entrepreuership..of business ownership? As it is, this is very hard work... and quite an investment in time, with the redeeming promise of helping the like minded eke out a living.. for their families. Along with the fact that $5.15 per hour, out in the workplace is not enough to pay our bills..certainly not enough pay to buy gas to TRAVEL to a JOB... Hello.... I am an Independent Busines Owner with AmeriPlan. A Senior Regional Sales Director, and a Council of Eagles Award Winner... I am very proud of my business and of my acomplishments. How could you consider to take away my dream of home entreprenuership.?! And supporting myself at age 60. I believe it is more important to have a seven day rule to buy a GUN... One of the most confusing and burdensome sections of the proposed rule is the seven day waiting period to enroll New BusinessOwners ? AmeriPlans sales kit only costs $_40_. People buy TVs, cars, and other items that cost much more than that and they do not have to wait seven-days. This waiting period gives the impression that there might be something wrong with the plan. I also think this seven-day waiting period is unnecessary, because AmeriPlan has a 90% buyback policy for all products including sales kits purchased by a salesperson within the last twelve months. Under this waiting period requirement, I will need to keep very detailed records when I first speak to someone about AmeriPlan and will then have to send in many reports to AmeriPlan headquarters. Who ever thought of this...? Even more preposterous..is the proposed rule that also calls for the " Release of any information" regarding lawsuits involving misrepresentation, or unfair or deceptive practices. It does not matter if the company was found innocent. Today, anyone or any company can be sued for almost anything. It does not make sense to me that I would have to disclose these lawsuits unless AmeriPlan is found guilty. Otherwise, AmeriPlan and I are put at an unfair advantage even though AmeriPlan has done nothing wrong. Independent Business Owners .. who are serious... can certainly find this information on the internet without any trouble... Finally, the proposed rule requires the disclosure of a minimum of 10 prior purchasers nearest to the prospective purchaser. I am glad to provide references, but in this day of identity theft, I am very uncomfortable giving out the personal information of individuals who have entrusted their info. with me. This proposal is ABSURD. Thank you for considering my comments Catherine Nolin